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U.S. Treasury tightens tax exemptions for foreign governments on U.S. passive income with new rules, effective 2025.
The U.S. Treasury has released final and proposed regulations under Section 892, clarifying tax exemptions for foreign governments on U.S. passive income.
The rules tighten the exemption by treating most debt acquisitions as commercial activities unless specific safe harbors apply, such as purchases in registered offerings or on established markets under strict conditions.
Passive investments in private funds may retain exemption if held as qualified partnership interests with limited control.
A de minimis safe harbor applies to holdings under 5%, and an inadvertent commercial activity exception offers relief with proper due diligence.
The regulations aim to prevent misuse while providing clarity, with public comments due by February 13, 2026.
El Tesoro de los Estados Unidos endurece las exenciones fiscales para gobiernos extranjeros en ingresos pasivos de los Estados Unidos con nuevas reglas, vigentes desde 2025.